Privacy Policy
Last updated: 22 October 2026
This Privacy Policy explains how Astral Media Group Limited, trading as Plutus Media ('Plutus', 'we', 'us' or 'our'), collects, uses, shares and otherwise processes your personal information when you:
- visit our website at https://www.byplutus.com, or any website of ours that links to this Privacy Policy;
- book or start booking a consultation, subscribe to our newsletter or download resources from our website;
- take part in a call or meeting with us; or
- engage with us in other related ways, including sales, marketing and events.
Astral Media Group Limited is the controller of your personal information. If you have questions, contact us at counsel@growwithplutus.net.
Summary of key points
What personal information do we process? Information you give us when you book a consultation, subscribe, attend a call or contact us, and information collected automatically when you use our website. See section 1.
Do we process sensitive personal information? No.
Do we collect information from other sources? Yes. We may obtain information from publicly available sources, data providers and business, advertising and analytics partners. See section 1.
How do we use your information? To arrange and prepare for consultations, communicate with you by email and text message, send marketing you can opt out of, analyse our website, advertise, keep our services secure and comply with the law. See section 2.
Who do we share it with? Service providers who work for us, our group companies, professional advisers and, where permitted, advertising, analytics and social media partners. See section 4.
Do we sell or share personal information? Under some US state laws, our use of advertising technologies and embedded social media content may count as a 'sale' or 'sharing' of personal information. You can opt out at any time. See section 12.
What are your rights? Depending on where you live, you can access, correct, delete or object to our use of your information, among other rights. See sections 10, 12 and 13.
How do you exercise them? Email us at counsel@growwithplutus.net.
Contents
- What information do we collect?
- How do we use your information?
- What legal bases do we rely on?
- When and with whom do we share your information?
- Do we use cookies and other tracking technologies?
- Is your information transferred internationally?
- How long do we keep your information?
- How do we keep your information safe?
- Do we collect information from minors?
- What are your privacy rights?
- Do-Not-Track and Global Privacy Control
- Do United States residents have specific privacy rights?
- Do other regions have specific privacy rights?
- Information you provide about others
- Embedded content from other websites
- Business contacts
- Do we make updates to this policy?
- How can you contact us?
- How can you review, update or delete your information?
1. What information do we collect?
Information you give us
When you book a consultation, we collect:
- your name, email address and phone number;
- information about your company, product and marketing, such as your product's website or app store listing, your company's stage, revenue, marketing spend, budget, timelines and goals;
- your answers to free-text questions; and
- the names, and any contact details you provide, of other people involved in your decision (see section 14).
If you start a booking but do not complete it, we may still receive the details you have entered, such as your name, email address and phone number.
When you subscribe to our newsletter or download a resource, we collect your name, email address and any other details the form asks for.
When you take part in a call or meeting with us, we may record it and create a transcript and notes. We will tell you at the start of the call if it is being recorded or transcribed.
When you contact us or deal with us in other ways, we collect the information you choose to share, for example in emails, messages or at events.
We do not ask for sensitive information, such as information about health, race or ethnicity, religion or sexual orientation. Please do not include it in free-text answers or messages.
Please make sure the information you give us is accurate, and tell us if it changes.
Information collected automatically
When you visit our website or open our emails, we and our service providers automatically collect some information about your device and how you use our website and communications. This information does not usually reveal your name or contact details, but it may still identify you, and we treat it as personal information.
- Log and usage data: your IP address, browser type and settings, the pages you view, the date and time of your visit, the page that referred you, and the actions you take on our website and in our emails.
- Device data: your device type, operating system, language settings, device and cookie identifiers, and internet service provider.
- Location data: your approximate location, such as your country, region or city, derived from your IP address. We do not collect precise geolocation data.
- Advertising and conversion data: the ads or campaigns that brought you to our website, actions you take after arriving (such as subscribing, downloading a resource or booking a call), and identifiers set by advertising platforms, such as cookie IDs and click IDs. Where permitted by law, we may share hashed (encrypted) versions of contact details, such as email addresses or phone numbers, with advertising platforms to measure our ads and show relevant ads to you and to similar audiences.
Information from other sources
We may obtain information about you and your business from other sources, including:
- publicly available sources, such as company websites, app store listings, social media and professional networking profiles;
- data providers and business information services;
- analytics and advertising partners, including information about the organisation associated with an IP address that visits our website; and
- business partners and people who refer you to us.
This may include your name, job title, business contact details, social media profiles and information about your company and its activity. We use it to understand your business, assess whether our services are relevant to you, keep our records up to date and improve our marketing.
2. How do we use your information?
We use your personal information for the purposes below. The legal basis column applies to you if you are in the UK or the European Economic Area (EEA); section 3 explains each basis. We will only use your information for a new purpose if it is compatible with these purposes, or with your consent.
| Purpose | What this involves | Legal basis (UK/EEA) | How long we keep it |
|---|---|---|---|
| Arranging and preparing for consultation calls | Scheduling the call you request, and reviewing the details you give us so we can prepare and assess whether our services suit your needs | Steps you ask us to take before entering a contract | 24 months from our last contact with you |
| Responding to enquiries | Answering questions and requests you send us | Steps before a contract, or legitimate interests | 24 months from our last contact with you |
| Delivering resources you request | Sending you the guides, reports and other content you ask for | Performance of a contract | 24 months from your request |
| Sending service messages | Booking confirmations, reminders and rescheduling notices by email or text message, and notices about changes to our terms and policies | Performance of a contract, or legitimate interests | 24 months from our last contact with you |
| Following up on enquiries, bookings and calls | Contacting you by email, phone or text message after you contact us, book a call or start but do not complete a booking, including sending relevant information and proposals | Legitimate interests, or consent where required by law | 24 months from our last contact with you |
| Recording and transcribing calls | Keeping accurate records of calls and meetings, following up on what was discussed, and improving the quality of our calls | Legitimate interests, or consent where required by law | 24 months from the call |
| Sending marketing communications | Our newsletter, and insights, resources and information about our services, by email or other channels | Consent, or legitimate interests for business contacts where the law allows; you can opt out at any time | Until you opt out; we then keep your contact details on a suppression list so we do not contact you again |
| Researching and verifying business contacts | Using public sources, data providers and partners to understand your business and assess whether our services are relevant to you | Legitimate interests | 24 months from collection |
| Analysing and improving our website and services | Using cookies and similar technologies to understand how visitors use our website and communications, and to improve them | Consent | Up to 26 months for analytics data |
| Advertising and measuring our marketing | Showing relevant ads on other platforms, building audiences, including from hashed contact details where permitted, and measuring the results of our campaigns | Consent | Up to 26 months; advertising platforms also keep data under their own policies |
| Protecting our website and services | Keeping our systems secure, preventing spam and fraud, and diagnosing technical problems | Legitimate interests | 12 months |
| Complying with the law and protecting our rights | Meeting legal and regulatory obligations, responding to lawful requests, and establishing or defending legal claims | Legal obligation, or legitimate interests | As long as the law requires or a claim may be brought |
| Protecting vital interests | Acting to prevent harm to someone where necessary | Vital interests | Only as long as necessary |
3. What legal bases do we rely on?
If you are in the UK or the EEA
The UK GDPR and the EU GDPR require us to have a valid legal basis for each use of your personal information. We rely on the following:
- Consent. We rely on your consent for non-essential cookies and similar technologies, for embedded social media content, and for marketing communications where the law requires it. You can withdraw consent at any time (see section 10).
- Performance of a contract. We process your information where we need to in order to provide something you have asked for, or to take steps at your request before entering into a contract with you.
- Legitimate interests. We process your information where it is necessary for our legitimate interests and those interests are not overridden by your rights and interests. Our legitimate interests include:
- responding to prospective clients and developing business relationships;
- following up on enquiries, bookings and calls;
- keeping accurate records of our calls and meetings;
- sending business contacts information about our services, insights and resources relevant to their work;
- identifying and qualifying prospective clients, and tailoring our communications to their needs;
- understanding and improving our services and marketing;
- keeping our website and systems secure, and preventing spam and fraud; and
- establishing, exercising or defending legal claims.
- Legal obligation. We process your information where we need to in order to comply with the law, for example tax and accounting rules, or to respond to a lawful request from a regulator or law enforcement body.
- Vital interests. In rare cases, we may process your information where necessary to protect someone's life or safety.
Where we rely on legitimate interests, you have the right to object (see section 10).
We may use automated tools to organise and prioritise enquiries. We do not make decisions that have legal or similarly significant effects on you based solely on automated processing.
If you are in Canada
We process your personal information with your express consent, or where your consent can reasonably be implied, for example when you book a consultation and we use your details to arrange it. You can withdraw your consent at any time, subject to legal or contractual restrictions.
In limited cases, the law allows us to process your information without consent. These include where processing is needed to investigate or prevent fraud or a breach of law, to comply with a subpoena, warrant or court order, in connection with a business transaction that meets legal conditions, or where the information is publicly available as defined by the regulations.
4. When and with whom do we share your information?
Service providers. We share personal information with service providers who perform services for us, under contracts that require them to use it only to provide those services and to keep it secure. They include providers of:
- website hosting and content management;
- scheduling, booking and customer relationship management;
- email, text messaging and other communication services;
- call recording, transcription and note-taking;
- data analytics;
- data enrichment and business information;
- marketing and advertising services;
- collaboration and productivity tools;
- cloud computing and data storage; and
- artificial intelligence services.
Advertising, analytics and social media partners. Where permitted by law, and with your consent where required, advertising networks, retargeting platforms, analytics providers and social networks receive information through cookies, pixels, tags and embedded content on our website, and through audience and measurement tools we use (see sections 5 and 15). Some of these partners use the information for their own purposes, including advertising, as independent controllers. Their use of it is governed by their own privacy policies.
Our group companies. We share information with companies in our group, including in the United States, which support our operations. They must handle your information in line with this policy.
Professional advisers. We may share information with our lawyers, accountants, auditors and insurers where needed for the advice or services they provide to us.
Legal requirements. We may disclose information where the law requires it, to respond to a lawful request from a public authority, or to establish, exercise or defend legal claims.
Business transfers. We may share or transfer information in connection with, or during negotiations of, a merger, sale of company assets, financing or acquisition of all or part of our business.
5. Do we use cookies and other tracking technologies?
Yes. We use cookies and similar technologies, such as pixels, tags, web beacons and software development kits, on our website and in our emails. They fall into these types:
- Strictly necessary: needed for the website to work and stay secure, and to remember your cookie choices. These do not need your consent.
- Functional: remember your preferences and support features such as booking forms.
- Analytics: help us understand how visitors use our website and communications.
- Advertising: measure the results of our campaigns and help show relevant ads on other platforms.
- Social media and embedded content: let you view content from social media platforms on our website (see section 15).
If you are in the UK or the EEA, we only use non-essential cookies and similar technologies after you consent through our cookie banner. You can change your choices at any time through the cookie settings on our website.
If you are in the United States, our use of advertising technologies may count as a 'sale' or 'sharing' of personal information under state law. You can opt out as described in section 12.
Some analytics and advertising providers also offer their own opt-out tools, which you can find in their privacy policies. You can also block or delete cookies through your browser settings, although some parts of our website may not work properly if you do.
Our Cookie Policy lists the cookies and similar technologies we use and what each one does.
6. Is your information transferred internationally?
Yes. We are based in the UK, and our team, group companies, service providers and partners operate in other countries, including the United States and countries in the EEA. Some of them may process information in other countries around the world.
The UK and the EEA recognise each other as providing adequate protection. When we transfer personal information from the UK or the EEA to a country without an adequacy decision, including transfers within our group, we use appropriate safeguards, such as:
- the European Commission's Standard Contractual Clauses;
- the UK International Data Transfer Addendum or the UK International Data Transfer Agreement;
- the recipient's certification under the EU-US Data Privacy Framework and its UK Extension; or
- other transfer mechanisms permitted by law.
You can ask us for more information about the safeguards we use by contacting us (see section 18).
7. How long do we keep your information?
We keep your personal information only for as long as we need it for the purposes in section 2, which lists the retention period for each purpose. We may keep information for longer where the law requires it, for example for tax or accounting purposes, or where we need it to establish or defend a legal claim. If you become a client, we keep your information in line with our contract with you.
When we no longer need your information, we delete or anonymise it. If that is not immediately possible, for example because it is held in backups, we store it securely and isolate it from further use until it can be deleted.
8. How do we keep your information safe?
We use appropriate technical and organisational measures to protect your personal information, including access controls and restricting access to people who need it for their work.
No method of transmitting or storing information over the internet is completely secure, so we cannot guarantee absolute security. If a security incident affects your personal information, we will notify the relevant authorities and, where required, you, in line with the law.
9. Do we collect information from minors?
No. Our website and services are for businesses and are not directed at anyone under 18, or the equivalent age set by law where you live. We do not knowingly collect personal information from, market to or sell the personal information of anyone under 18. By using our website, you confirm that you are at least 18.
If we learn that we have collected personal information from someone under 18, we will delete it promptly. If you believe we hold such information, contact us at counsel@growwithplutus.net.
10. What are your privacy rights?
If you are in the UK, the EEA, Switzerland or Canada, you have rights over your personal information. Depending on the circumstances, you can:
- ask for access to, and a copy of, your personal information;
- ask us to correct inaccurate or incomplete information;
- ask us to delete your information;
- ask us to restrict how we use your information;
- ask to receive your information in a portable format;
- object to our use of your information where we rely on legitimate interests; and
- object at any time to our use of your information for direct marketing, in which case we will stop.
To exercise these rights, email us at counsel@growwithplutus.net. We will respond within one month. For complex or numerous requests, we may extend this by up to two further months and will tell you if we do. We may need to verify your identity first. We do not normally charge a fee.
Withdrawing consent. Where we rely on your consent, you can withdraw it at any time by contacting us, or for cookies by changing your cookie settings on our website. Withdrawing consent does not affect processing that took place before you withdrew it.
Opting out of marketing. You can opt out at any time by using the unsubscribe link in our emails, replying STOP to our text messages, or contacting us. We may still send you service messages, such as booking confirmations.
Complaints
If you are unhappy with how we have handled your personal information, please contact us first at counsel@growwithplutus.net. We will acknowledge your complaint within 30 days, investigate it without undue delay, keep you informed and tell you the outcome.
If you are in the UK and are not satisfied with our response, you can complain to the Information Commissioner's Office (ICO):
- Website: ico.org.uk/make-a-complaint
- Helpline: 0303 123 1113
- Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
If you are in the EEA, you can complain to the data protection authority in the country where you live or work, or where you believe a breach occurred. If you are in Switzerland, you can contact the Federal Data Protection and Information Commissioner.
11. Do-Not-Track and Global Privacy Control
Some browsers offer a Do-Not-Track (DNT) setting. There is no agreed standard for responding to DNT signals, so we do not currently respond to them.
We do recognise and honour Global Privacy Control (GPC) signals. If your browser or an extension sends a GPC signal, we treat it as a request to opt out of the sale or sharing of your personal information for targeted advertising, and apply it automatically without you needing to do anything else. To learn more about GPC, visit globalprivacycontrol.org.
12. Do United States residents have specific privacy rights?
Yes. If you live in California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, Virginia or another state with a comprehensive privacy law, you may have the rights described below. These rights depend on the law of your state and may be limited in some circumstances.
Categories of personal information we collect
| Category | What this includes for us | Collected in the past 12 months |
|---|---|---|
| A. Identifiers | Name, email address, phone number, IP address, cookie and online identifiers | Yes |
| B. Personal information under the California Customer Records statute | Name, phone number and business information | Yes |
| C. Protected classification characteristics | Such as age, gender, race or ethnicity | No |
| D. Commercial information | Services you have considered buying from us, such as the budget and timeline you share when booking | Yes |
| E. Biometric information | Such as fingerprints or voiceprints used for identification | No |
| F. Internet or other network activity | Pages viewed, and interactions with our website, emails and ads | Yes |
| G. Geolocation data | Approximate location derived from your IP address; no precise geolocation | Yes |
| H. Audio, electronic, visual or similar information | Recordings and transcripts of calls and meetings | Yes |
| I. Professional or employment-related information | Your company, job title, role in buying decisions and the colleagues you name | Yes |
| J. Education information | Such as student records | No |
| K. Inferences | Conclusions drawn from the information above, such as whether your business may be a fit for our services and your likely interests | Yes |
| L. Sensitive personal information | Such as government ID, financial account details or precise geolocation | No |
We keep each category for the periods set out in section 2. In general, this is up to 24 months from our last contact with you, and up to 26 months for analytics and advertising data. If you opt out of marketing, we keep your contact details on a suppression list so we do not contact you again.
Sources. We collect this information from you, automatically from your device, and from the other sources described in section 1.
Purposes. We use this information for the purposes described in section 2.
Disclosure, sale and sharing
We disclose each category we collect to service providers and contractors for business purposes, under written contracts. The types of recipients are listed in section 4.
In the past 12 months, we may have sold or shared categories A (identifiers), B (Customer Records information), D (commercial information), F (internet activity), G (approximate geolocation) and K (inferences) through advertising cookies, pixels, tags, audience tools and embedded social media content. The recipients are advertising networks, retargeting platforms, analytics providers and social networks. We do not sell personal information for money, and we do not knowingly sell or share the personal information of anyone under 16.
We do not collect or process sensitive personal information.
We do not offer payments, discounts or price differences in exchange for your personal information.
Your rights
Depending on your state, you may have the right to:
- know whether we process your personal information, and access it;
- correct inaccuracies;
- delete your personal information;
- obtain a copy of the personal information you gave us;
- opt out of the sale or sharing of your personal information, targeted advertising, and profiling that produces legal or similarly significant effects;
- obtain a list of the categories of third parties, or the specific third parties, to which we have disclosed or sold your information, where your state law provides this; and
- not be discriminated against for exercising your rights.
How to exercise your rights
- Opt out of sale, sharing and targeted advertising through the 'Your Privacy Choices' link on our website or the cookie settings on our website. We also honour Global Privacy Control signals (see section 11).
- For other requests, email us at counsel@growwithplutus.net.
We will respond within 45 days, or longer where the law allows, and will tell you if we need more time. We will verify your identity using information we already hold, and may ask for more information if needed.
Authorised agents. You can use an authorised agent to make a request for you. We may ask for signed proof of their authority and verify your identity directly.
Appeals. If we decline your request, you can appeal by emailing counsel@growwithplutus.net. We will tell you in writing what action we have taken, with our reasons. If your appeal is denied, you can complain to your state attorney general.
California 'Shine the Light' law
California residents may ask us, once a year and free of charge, for information about the personal information we disclosed to third parties for their own direct marketing purposes in the previous calendar year. To make a request, contact us using the details in section 18.
13. Do other regions have specific privacy rights?
Canada, including Quebec
We process personal information of people in Canada under the Personal Information Protection and Electronic Documents Act (PIPEDA) and, for Quebec residents, the Act respecting the protection of personal information in the private sector.
You can access and correct your personal information, withdraw your consent, and ask to be told when a decision about you is based solely on automated processing. Quebec residents can also ask for their information in a portable format and ask us to stop disseminating it. To make a request, use the details in section 18.
The person in charge of the protection of personal information at Plutus is our Privacy Lead, who can be contacted at counsel@growwithplutus.net.
We store and process personal information outside Quebec and Canada, including in the United Kingdom and the United States, as described in section 6.
If you are not satisfied with our response, you can complain to the Office of the Privacy Commissioner of Canada or, in Quebec, the Commission d'accès à l'information.
Switzerland
We process personal information of people in Switzerland under the Federal Act on Data Protection (FADP). You have rights similar to those in section 10. You can contact the Federal Data Protection and Information Commissioner if you have concerns.
Australia
We process personal information of people in Australia under the Privacy Act 1988 and the Australian Privacy Principles. This policy explains what we collect, from which sources, why and who we share it with. We disclose personal information to recipients outside Australia, including in the United Kingdom, the United States and the EEA, as described in sections 4 and 6.
If you do not give us the information we need, we may not be able to arrange a consultation or respond to your request. You can ask to access or correct your personal information using the details in section 18. If you believe we have breached the Australian Privacy Principles, you can complain to the Office of the Australian Information Commissioner.
14. Information you provide about others
When you book a consultation or deal with us, you may give us the names and contact details of colleagues or other people involved in your decision. Please only share this information if you have their permission, or if it is reasonable to expect that they would want to be included. We use it to arrange and follow up on the consultation and our discussions, and keep it for the same period as your own information. If you are one of these people and would like us to stop contacting you, contact us using the details in section 18.
15. Embedded content from other websites
Our website may include embedded content from third-party platforms, such as videos and posts from social media platforms. Embedded content behaves in the same way as if you had visited the other website. These platforms may collect information about you, such as your IP address, device information and the page you are viewing, use cookies, and track your interaction with the content. They may use this information for their own purposes, including advertising, and may process it outside the UK and the EEA.
If you are in the UK or the EEA, we only load embedded content that uses non-essential cookies after you consent through our cookie banner. For more information, see the privacy policies of the relevant platforms.
16. Business contacts
Our services are for businesses. Most of the personal information we process relates to people acting in a professional capacity, such as founders, marketing leads and other representatives of businesses that use or are considering our services. This information is still personal information, and you have the same rights over it as described in this policy.
17. Do we make updates to this policy?
We may update this policy from time to time, for example when our practices or the law change. The 'Last updated' date at the top shows when it was last revised. If we make material changes, we will tell you by posting a prominent notice on our website or by contacting you directly.
18. How can you contact us?
Email: counsel@growwithplutus.net
Post:
Astral Media Group Limited
Fitzrovia House
3–5 Gower Street
London WC1E 6HA
England
19. How can you review, update or delete your information?
You can ask to access, correct or delete the personal information we hold about you, or to withdraw your consent, subject to the law. To make a request, email us at counsel@growwithplutus.net. Sections 10, 12 and 13 explain the rights that apply where you live.
